Licences and Proprietary Estoppel Lecture

LICENCES

Licences are certainly the lowest-ranking category of property rights. There are four kinds of licences which exist in English law: bare licences; contractual licences; licences coupled with an equity; and licences coupled with an interest.

Bare licences

A bare licence is simply the giving of personal permission by the landowner for the licensee (the person with the benefit of the licence) to enter and remain on the land. The licensee will not be required to provide consideration for accessing the land. So long as the licence runs, it acts as a defence for the licensee against any charge of trespass, so long as the licensee has complied with the scope of the licence (Tomlinson v Congleton BC [2003] 3 WLR 275 per Lord Hutton and Lord Hobhouse of Woodborough). As Scrutton LJ observed in The Calgarth [1927] P 93 Coram. A bare licence effectively confers the right only of not being a trespasser so long as they comply with the terms of the licence; it does not confer any higher status than that. In a licence ‘properly passeth no interest nor alters or transfers property in anything, but only makes an action lawful, without which it had been unlawful’ (Thomas v Sorrell [1673] EWHC (KB) J85 per Vaughan CJ). Therefore, a licensee may not transfer what few rights they have to another party. The licensee’s rights are vested in themselves, not the land, and are thus wielded only against the landowner where those rights of access are unlawfully infringed.

Creation

A bare licence may be created orally and be express or implied. Given their somewhat informal nature they often arise by circumstances or conduct (R (Beresford) v Sunderland CC [2003] UKHL 60 per Lord Rodger of Earlsferry and Lord Walker of Gesingthorpe). It is by this means that a trespass may shift into a bare licence where the landowner has knowledge of the trespass and gives no objection to it (Canadian Railway Co v The King [1931] UKPC 18 per Lord Russell of Killowen). There is an implied licence granted by homeowners for persons to pass through the homeowner’s front gate and towards the front door in order to request permission to enter the property (Robson v Hallett [1967] 2 QB 939). Parents of schoolchildren are also entitled to limited access of the school in order to determine the location and wellbeing of their child (Wandsworth LBC v A [2000] 1 WLR 1246, CA).

Bare licences and trespass

The threshold between a licence and trespass is small and easily transgressed. As has been observed by Lord Camden CJ: ‘By the laws of England every invasion of land, be it ever so minute, is a trespass. No man can set his foot upon my ground without my licence’ (Entick v Carrington [1765] EWHC KB J98). Thus, the licensor retains the right of arbitrary exclusion, meaning they can choose to exclude the licensee at any time for any duration. It is possible, but rare, that arguments of necessity and public purpose can surmount this right (Monsanto v Tilly [1999] EWCA Civ 3044).

Contractual licence

A contractual licence is similar to a bare licence insofar as it grants the licensee permission to access the land. Where the two kinds of licences differ is that the contractual licence includes the giving of consideration by the licensee for the benefit of the licence (Horrocks v Forray [1976] 1 WLR 230 per Megaw LJ). The underlying contract may be either express or implied.

Examples of everyday contractual licences include cinema tickets and sports events tickets. A building contractor obtains a licence to work on the land over which they are contracted. Yet in all these instances, they cannot be described as conferring on the licensee a proprietary interest in the land (Cowell v Rosehill Racecourse Co Ltd (1937) 56 CLR 305 per Latham CJ).

A contractual licence is terminable upon the end of a fixed term, without any requirement of notice (Sandhu v Farooqi [2003] EWCA Civ 531). It was once the position that a licensor could prematurely terminate a licence and therefore the right of occupation by the licensee even if such a termination amounted to a breach of contract (Wood v Leadbitter (1845) 13 M&W 838). However, the case law has changed, such that premature termination or revocation by the licensor will prevent the licensor from excluding the licensee for the duration of the remaining fixed period (Winter Garden Theatre (London) Ltd v Millennium Productions Ltd [1948] AC 173), such that the licensee may even be able to obtain an injunction of specific performance requiring the licensor to allow them on to the property for the remainder of the contractual period (Verrall v Great Yarmouth BC [1981] QB 202).

Licences coupled with an equity

The notion of licences coupled with an equity has been an enduring form of licences, stemming from at least the early 17^th century (Webb v Paternoster (1619) 2 Roll. Rep. 143). Unlike a bare licence, a licence coupled with an equity may not be terminated simply upon the wish of the licensor (the party which is burdened by the licence). These sorts of licences are found in situations where the landowner ‘grants a licence to another [person] to go upon land and occupy it for a specific period or a prescribed purpose, and on the faith of that authority the licensee enters into occupation and does work, or in some other way alters his position to his detriment’ (National Provincial Bank Ltd v Hastings Car Mart Ltd [1965] UKHL 1). The court will uphold the licence in order to prevent the licensor from acting in such a way as to frustrate the purpose of the licence.

Licences and proprietary estoppel

As you will see, this concept of a licence coupled with an equity is very similar to the framework of rights granted in proprietary estoppel. Those latter rights have come to accommodate a binding effect on third parties (Land Registration Act 2002, s.116(a)). We can see the overlap between the two doctrines in the case which immediately follows:

Key Points:

• The licensee’s status changed upon moving from a protected tenancy to an unprotected licence.
• The loss of protection was deemed to be the consideration.
• Given the property right was “merely” a licence the court could only award damages.
• The court said there was an “implied” contract, and the unlawful termination of that contract entitled the licensee to said damages.
• In other cases, the court has preferred to invoke other types of property rights i.e. proprietary estoppel and equitable licences.

Licences coupled with the grant of an interest

This type of licence confers upon the licensee the right to go on another person’s land for the sole purpose of removing something from the land (such as timber, minerals, and crops). This licence therefore includes the rights granted under profits à prendre to access an interest, coupled with the right to enter land in order to exploit the interest. The licence cannot be revoked during the exercise of the licence (Wood v Leadbitter (1845); and Hounslow LBC v Twickenham Garden Developments Ltd [1971] Ch 233). The licence is beneficial to the holder of the licence in two ways: first, it is binding on both the licensor and their successors in title (Webb v Paternoster (1619). Second, it is capable of being assigned by the licensee to a third party (Muskett v Hill (1839) 5 Bing (NC) 694).

Licences and third parties

As we have seen, a bare licence creates a merely personal right between the licensor and licensee. The right cannot be assigned by the licensee to a third party, nor is it binding on a third party successor of the licensor. Conversely, equitable licences and licences coupled with an interest are capable of binding a third party. The real dilemma lies with contractual licences, given their close similarity to proprietary estoppel.

Broadly, the case law says that ‘a contractual licence does not create a property interest’, meaning it is not binding against third parties (Ashburn Anstalt v Arnold [1988] EWCA Civ 14 per Fox LJ; Lloyd v Dugdale [2001] EWCA Civ 1754 per Sir Christopher Slade). This position has been maintained by the court at various points for a long period (King v David Allen and Sons, Billposting, Ltd (1916) 2 AC 54).

This view was not universally held, however. For example, Lord Denning MR suggested contractual occupation licences ought to be able to ‘override’ transactions in registered land, meaning that the licence would bind the third party purchaser, particularly in the context of long-running residential occupation licences (National Provincial Bank Ltd v Hastings Car Mart Ltd [1965]). However, the Court of Appeal has subsequently rejected this notion, particularly in Ashburn Anstalt v Arnold [1988]. It is therefore highly unlikely that, in registered land, a contractual licence will be deemed capable of so affecting a third party purchase that the third party is bound by the licence (Habermann v Koehler and another [2000] All ER (D) 1739).

Licences and constructive trusts: overlap?

For contractual licences and unregistered land, there may be instances in which they are enforceable by means of a constructive trust. Usually, a contractual licence is not necessarily capable of binding a third party purchaser. Although it had once been said to be possible as such (Binion v Evans [1972] EWCA Civ 6), subsequent case law has determined that a third party purchaser will only be bound by a contractual licence where the circumstances amount to a constructive trust. A greater focus is placed on the conscience of the third party than on the substance of the rights of the contractual licensee (Melbury Road Properties 1995 Ltd v Kreidi (1999) 3 EGLR 10). Such a trust would arise where:

1. A third party has of their own volition ‘burdened their own title’ upon making their own obligation to the contractual licensee (Bahr v Nicolay (No. 2) [1988] HCA 16 per Brennan J); and/or
2. The transfer of the property to the third party was based in part on the sale of the property at a lower than market value, with such sale given on the understanding that the terms of the contractual licence would be upheld (Ashburn Anstalt v Arnold [1988] per Fox LJ).

With all that said, there is an exception in contractual licences, according to which the licence may be binding against third parties where the licence is protected by way of a register entry. In the case of Donington Park Leisure Ltd v Wheatcroft & Sons Ltd [2006] All ER (D) 94 (Apr) the court held that a contractual licensee, upon being granted ‘guaranteed’ parking rights on a lot, was entitled to have that right registered as a restriction in the licensor’s register of title so as to protect the licensee in the event those rights would otherwise by lost by means of transfer of the property to a third party. Thus, the proprietary character of the right - in this limited circumstance - provides an effective remedy against third parties (Yanner v Eaton [1999] HCA 53 per Gummow J).

Further, it appears that some licensees may actually be acquiring some proprietary interests against third parties by way of possession: a contractual licensee may sue in trespass if he has exclusive possession (Hounslow LBC v Twickenham Garden Developments Ltd [1971]), and where there is a licence coupled with an interest (meaning to enter land and remove certain products such as timber from the land), the licensee has rights against parties that trespass on the land and prevent the licensee from carrying on their activity (Manchester Airport v Dutton [1999] EWCA Civ 844).

PROPRIETARY ESTOPPEL

The doctrine of proprietary estoppel is based on ‘the first principle upon which all courts of equity proceed… [which is] to prevent a person from insisting on his strict legal rights - whether arising under a contract, or on his title deeds, or by statute - when it would be inequitable for him to do so having regard to the dealings which take place between the parties’ (Crabb v Arun DC [1975] EWCA Civ 7 per Lord Denning MR).

The purpose of proprietary estoppel is to refrain, or ‘estop’, any attempt by a legal owner to inequitably go back on guarantees made by them in the course of dealing with another party regarding the owner’s land. It is invoked in family law disputes when attributing shares between the parties, and is also invoked to resolve business disputes, given that equity is ‘flexible and strong enough to ensure that any estoppel results in a sensible commercial outcome, which is not thwarted by archaic and technical rules of property law, unless those rules are based on public policy or are so fundamental as to be incapable of being overridden’ (PW & Co v Milton Gate Investments Ltd [2003] EWHC 1994 (Ch) per Neuberger J).

The advantage of proprietary estoppel is that it can help to make sense of, and thereby enforce, the sorts of arrangements that are entered into by laypersons, particularly licences.

In order for a landowner to be “estopped” from carrying on a certain act, it must be shown that in the ‘particular individual circumstances, it would be unconscionable for a party to be permitted to deny that which, knowingly or unknowingly, he has allowed or encouraged another to assume to [the denying party’s] detriment’ (Taylors Fashions Ltd v Liverpool Victoria Trustees Ltd [1982] QB 133 per Oliver J). Relief will thus be granted if to do so would be ‘just’ (Sledmore v Dalby (1996) 72 P & CR 196 CA (Eng) per Hobhouse LJ).

Essential Elements

A claim of proprietary estoppel depends on the person claiming the benefit being able to prove three elements (Thorner v Major [2009] UKHL 18 per Lord Walker of Gesingthorpe and Lord Neuberger of Abbotsbury):

1. Representation

Representation is shown where the representor (the person making the representations) intended for their assurances to the representee (the person to whom the representations were made) to be relied upon (Matharu v Matharu(1994) 26 H.L.R. 648, CA (Eng)). A representation is essential: a mere expectation of rights is not enough, because what is required is that the landowner has at some point encouraged or allowed any belief or expectation on the representee’s part that the latter would attain rights (Parker v Parker [2003] All ER (D) 421 (Jul). A long-standing practice will not suffice (Keelwalk Properties Ltd v Waller [2002] EWCA Civ 1076).

Subject matter

The subject of the representation can take the form of almost any property right, so long as the assurance made was ‘clear and unequivocal’ (Thorner v Major [2009] per Lord Scott of Foscote and Lord Neuberger of Abbotsbury). The test is whether the estoppel claimant, as a reasonable person, was led to believe that they had acquired or would acquire rights over the land based on the statement(s) made to them (Parker v Parker [2003]).

Key Points:

• The representor made representations to the representee that the house and its contents would thereafter belong to the representee.
• The representee subsequently made repairs to the property.
• The Court said this sequence of events meant, according to the doctrine of proprietary estoppel, that the claimant was entitled to the title of the property, not merely compensation.

Unclear representations

If the representations are not of a ‘sufficiently concrete character’, the claimant is not reasonably entitled to expect the alleged rights flowing from the representation (Orgee v Orgee [1997] EWCA Civ 2650). Even if the representor’s resiling from the representation is unconscionable, the detriment may be so uncertain in nature and extent ‘that even equity may not be able to devise an appropriate remedy for it… There are parts that sometimes even equity cannot reach’ (Willis v Hoare (1999) 77 P & CR D42 per Auld LJ). For example, no equity arises upon the legal owner assuring the representee of ‘financial security’ before and after the representor’s death where no reference is made to specific assets (Layton v Martin [1986] 2 FLR 227). Likewise, a statement by the representor that the representee ‘did not need to worry her pretty little head about money’ was not sufficiently concrete and specific (Lissimore v Downing [2003] 2 FLR 208).

2. Reliance

Reliance occurs where the representee has changed their position and suffered a detriment because of the assurances received from the representor. This is effectively a requirement of causation: the change of position had to follow from a representation by the representor (Gillett v Holt [2001] Ch 210). This causal link is absolute; its absence will invalidate any claim for proprietary estoppel (Philip Lowe (Chinese Restaurants) Ltd v Sau Man Lee unreported, 9 July 1985, CA).

However, if the representee is able to prove they suffered a detriment, the burden of proof shifts to the representor. The representor has to prove that the change of position was not caused by a statement they themselves had made (Wayling v Jones(1993) 69 P & CR 70, CA (Eng)). Further, it is not necessary that the representation be the only inducement to cause the representee to change their position, so long as the representation was among the causes (Campbell v Griffin [2001] EWCA Civ 990, CA (Eng) per Robert Walker LJ).

Knowledge

The person claiming proprietary estoppel cannot do so unless the representor had knowledge, either actual or constructive, of the representee acting in reliance on the expectation of a benefit following the representor’s representation. If the representor does not have such knowledge, the claim fails (Barclays Bank plc v Zaroovabli [1997] Ch 321).

Change of position

There has to be evidence of a “relevant” disadvantage incurred by the claimant when they act upon the representation made by the representor. The required change, again, only needs to be relevant, and is ‘not a narrow or technical concept’ (Gillett v Holt [2001] per Robert Walker LJ), which means it is case-sensitive and takes into account informal dealings that were nevertheless intended to be binding. The form that the change takes has to be ‘distinct and substantial’ (Sledmore v Dalby(1996)). The usual method by which change of position is demonstrated is where the claimant expends money or resources in improving or maintaining the landowner’s property (Dillwyn v Llewelyn [1862] EWHC Ch J67).

Here follows other examples of change of position that were upheld by the court as relevant:

1. Leaving an existing job and home in order to live with the representor (Jones (AE) v Jones (FW) [1977] 1 WLR 438);
2. Completely attending to ‘all the functions of a live-in carer’ (Campbell v Griffin [2001]);
3. Using, but failing to reserve, a right of way (Crabb v Arun DC [1975]); and
4. Not taking up offers of employment on the basis of representations regarding other employment or other means of self-financing (Gillett v Holt [2001]).

Key Points:

• The representor had made repeated statements to the representee in his wills (a formal document) of promises of land to the representee.
• Given these statements, the representee had agreed to undertake unpaid work on the representor’s land, thereby benefitting the land. The representee did so for over 40 years.
• The weight of these two factors meant that the statements were not revocable, as is usually the case for wills, but were ‘tantamount to a promise.’

3. Detriment

Detriment is shown when the representation, once made and relied upon, has been unconscionably withdrawn. The unconscionable withdrawal is key to this step: no actionable disadvantage is deemed to accrue until the original representation is withdrawn or revoked (Grundt v Great Boulder Pty Gold Mines Ltd [1937] HCA 58 per Dixon J). The test for the claimant is to demonstrate that the withdrawal of the representation causes such ‘prejudice… that it would be inequitable to allow the party who made the relevant representation to go back on it’ (Watts and Ready v Storey (1984) NLJ 631 301 per Slade LJ).

Standard of unconscionability

When the representor insists on enforcing their solely legal right, they must do so in a manner and in such timing that they are ‘taking advantage of [the representee] in a way which is unconscionable, inequitable or unjust’ (Crabb v Arun DC [1975] per Scarman LJ). The unconscionability is in part measured by the material detriment suffered by the claimant. If the claimant actually incurs an advantage or advantages from the resiling of the representation, and regardless of whether those advantages are intended or not by the representor, then the sum of those advantages may outweigh, and therefore negate the claimant’s claim (Wilkie v Redsell [2003] All ER (D) 154 (Jun)).

Duration of equity

The courts have been willing to keep the doctrine of proprietary estoppel flexible insofar as its timing is concerned. The court provides as follows: so long as the detriment is not removed or that the claimant’s inequitable loss is not compensated, the claimant retains a claim in proprietary estoppel (Commonwealth of Australia v Verwayen (1990)170 CLR 394 per McHugh J). Conversely, once the hitherto-inequitable detriment is ‘ceased or been paid for’, the court will say there is ‘nothing unconscionable in a party insisting on reverting to his or her former relationship with the other party and enforcing his or her strict legal rights’ (Commonwealth of Australia v Verwayen (1990) per McHugh J).

Key Points:

• The claimant had carried out substantial works. This was the change of position.
• They had relied on statements made to them by the husband of the defendant that carrying out those works would result in rent-free accommodation for life. This was the representation.
• The person making the representation died and the claimant started living elsewhere.
• The defendant’s needs changed, such that she chose to resile from the original representation of rent-free accommodation for life. This would have been the detriment.
• However, given the passage of time and the changes in the needs of the respective parties, the court held that an enduring equity had since expired.
• Therefore, there was no unconscionability.

Proprietary estoppel and third parties

NOTE: It should be remembered that the word “proprietary” in “proprietary estoppel” does not refer to the effect it has on third parties. In land law, when we speak of rights taking effect only between two or more initial parties to an agreement, their rights are personal. They cannot be assigned to third parties later in time. When we speak of rights having a proprietary character, we mean that the rights and liabilities of the agreement can be transferred to third parties.

The earliest case law which considered whether a benefit or burden can be transferred to a third party indicated that proprietary estoppel was merely a personal right and therefore incapable of assignment to a third party (Jones (AE) v Jones (FW) [1977]). However, the case law has changed somewhat.

The benefit of a proprietary estoppel is capable of assignment, not just by the original party relying on the assurance, but also by a successor in title to the original party (Cameron v Murdoch (1986) 63 A.L.R. 575).

Transmitting the burden of a proprietary estoppel has also seen a similar evolution. Prior to the enactment of the Land Registration Act (LRA) 2002, the court had seen in estoppel a sufficiently proprietary character that made it possible for the burden of a proprietary estoppel to be assigned from the original representor to successors in title (Lloyd v Dugdale [2001]). Subsequently, the LRA 2002 provides that an ‘equity by estoppel’ takes effect ‘from the time the equity arises an interest capable of binding successors in title’ (LRA 2002, s.116(a)). It ought to be borne in mind however is that the burden of a proprietary estoppel can only be effectively transferred to a third party if the conscience of that third party is somehow compromised by the estoppel. If the conscience of the third party is not so affected, they are free to disregard the proprietary estoppel. Thus, when looking to see if a proprietary estoppel has affected the conscience of a third party, the court will look at it on a case-by-case basis, independently of the conscience of the original representor.

Proprietary estoppel and constructive trusts: overlap?

Some have suggested that the overlap between proprietary estoppel and constructive trusts is so strong that the two concepts are effectively interchangeable (Birmingham Midshires Mortgage Services Ltd v Sabherwal [2000] 80 P & CR 256 per Robert Walker LJ). One distinction between the two concepts is the notion of bargaining, or lack thereof. Constructive trusts require a bargaining between the two parties, whereas proprietary estoppel merely requires that the representor has observed the representee incur disadvantage by relying on the representor’s previous statement(s) (Yaxley v Gotts [2000] Ch 162 per Robert Walker LJ and Beldam LJ).

HANDS-ON EXAMPLES

Given that we have been examining two discrete areas of property law, it makes sense to separate the elements that guide the application of each of these forms of property rights. Thus, when analysing a problem question pertaining to these areas, we can summarise the steps taken as follows:

Licences

(Establishing that the right is a licence):

1. Is the person claiming a right of occupation?
2. Has the landowner granted permission to remain on the land but has not granted any further rights e.g. the right to possess the land?
3. If yes, go to steps 4 and following below.

(Establishing the type of licence):

4. Is the licence a bare licence?
5. Alternatively, is it a licence coupled either with an equity or an interest?
6. If neither of the above, the licence is a contractual licence.

If you answer “yes” to 4, the licensee may be excluded at any time (remember: arbitrary exclusion). If you answer “yes” to 5, the licensee can remain on the land for a set duration and may have rights against third parties. If you answer “yes” to 6, the licensee’s rights of occupation will last only according to the term set by the agreement.

Proprietary estoppel

(Establishing that the right is a proprietary estoppel):

1. Has there been a clear and unequivocal statement relating to a promise of a specific asset, or assets, in exchange for a certain act or acts? If not, go to step 5.
2. If “yes”, has the person to whom the statement was made altered their position to their own detriment? If not, go to step 5.
3. If “yes”, has the person who made the statement since revoked that statement in a manner which disadvantages the representee and is done in a time and manner which is unconscionable? If not, go to step 5.
4. If “yes” to all the above, there is a right of proprietary estoppel.
5. If “no” to any of 1-3, there is no proprietary estoppel.

Q1. Albus and Bertha purchase a house and they allow their son-in-law, Charlie, to live with them. Charlie offers to improve some of the roof tiles and construct a conservatory at his own expense. Albus agrees to this and says Charlie can live in the house rent-free for the rest of his, Charlie’s, life if he does so. Bertha is aware of the arrangement, and does not expressly agree or disagree to it/ Charlie thus conducts those works. Some years later, Albus has died and Bertha needs to adapt the house for her own needs. She needs to have Charlie excluded from the property.

Advise Bertha.

Q2. Dangerous Productions (DP) are hoping to stage a risqué political event at an events centre in Ealing for five consecutive nights. Ealing Borough Council, owners of the centre, agree to let DP stage the event upon payment. DP duly make the required payment. After the first night, Ealing Council receive complaints about the language used in the production, and decide to “uphold the morals of the community” by forbidding DP from entering the centre again to stage the subsequent events.

Advise DP.

Q3. Frank is the owner of Blackacre. He invites Geoff over to the property, and upon seeing his guest says Geoff can “stay for as long as he likes.” No money changes hands. Geoff stays for several weeks. The two get into an argument and Frank tells Geoff that Geoff has to leave. Geoff refuses, saying he was entitled to stay.

Advise Frank.

Q4. Zack owns Whiteacre, a large plot of farmland. He invites an acquaintance, Yasmin to the farmland. She tells Zack that she has long wanted to work on a farm, and starts to do so without payment. Zack is impressed by the quality of her work and amends his will to say that Yasmin would be entitled to a portion of the farmland. As she continues to work on the farm, Zack further amends his will, increasing the size of Yasmin’s portion of the farmland. Zack and Yasmin fall out, and Zack amends his will in such manner that Yasmin would not be entitled to any part of Whiteacre.

Advise Yasmin.

A1. This case follows the precedent set by Sledmore v Dalby. As you will recall from that case, the passage of time and the changing needs and priorities of the parties was such that the equity, which had validly arisen, was now extinguished. Following this precedent, Bertha is free to exclude Charlie from the property without needing to compensate him.

A2. This is a contractual licence situation: payment has been made for temporary occupation of space owned by the landowner for a fixed duration. Given that Ealing have attempted to interfere with the exercise of the contract by prematurely revoking the right of access and occupation, DP are entitled to continue staging their event for the duration stated in the licence, and to force Ealing to let them stage the event (see Verrall v Great Yarmouth BC).

A3. The situation here is that of a bare licence. This is because there is no exchange of money. As the owner, Frank is at liberty to revoke permission for occupation of the property at any time. There does not appear to be any grounds of necessity or public purpose, therefore Frank can lawfully arbitrarily exclude Geoff from the property.

A4. The facts in this case resemble the facts in Gillett v Holt. As you will recall, in that case all of the elements of proprietary estoppel were found to subsist, such that they overcame the usually revocable effect of a will to make the representations ‘tantamount to a promise.’ We see that in this case: unpaid work, promises of land being made for ever-increasing size, and then a resiling from those statements. Therefore, Yasmin is entitled to compensation and, following Gillett, the plot of land heretofore promised to her.

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